We work with loyalty, fairness, transparency, integrity, in full compliance with laws and regulations.
In line with the principle of “zero tolerance” expressed in the company’s Code of Ethics, Eni addresses the high risks that the company faces in carrying out its business activities with an articulated system of rules and controls for the prevention of corruption (the so-called Anti-corruption Compliance Program). Eni’s Anti-Corruption Compliance Program, prepared in accordance with applicable anti-corruption provisions and international conventions, is characterized by its dynamism and constant attention to the evolution of the national and international regulatory landscape and best practices. Eni’s experience in anti-corruption issues evolves also through ongoing participation in international conferences and workshops that help Eni to grow, promote and spread its values (PACI, B20, United Nations Global Compact, Foundation Global Compact Network Italy, ABC Benchmarking Group and OECD).
Current anti-corruption regulations at Eni are outlined in the Anti-Corruption Management System Guidelines that identifies areas at risk of corruption and sets out the general principles to be observed in conducting activities in such areas, as well as specific anti-corruption and bribery tools detailing the applicable regulations for the management of individual business processes at risk of corruption.
The adoption and implementation of the Compliance Program is mandatory for Eni SpA and all its subsidiaries in Italy and abroad, each of which adopt it by resolution of the Board of Directors. Companies or entities in which Eni does not have a controlling interest are also required to comply with the standards set out in the anti-corruption regulations, as well as maintaining an adequate internal control system, in line with the provisions of anti-corruption laws.
To ensure the effectiveness of Eni’s Anti-Corruption Compliance Program, a dedicated organisational structure was created, with the task of providing specialised anti-corruption assistance to Eni and its unlisted subsidiaries in Italy and abroad. This unit is managed directly by the “Integrated Compliance” Department, which in turn reports directly to the chief executive of Eni SpA.
Conscious that the first element for the development of an effective anti-corruption strategy is a thorough knowledge of available prevention tools, Eni, through the anti-corruption unit, in 2009, launched a comprehensive awareness raising and training initiative, through a structured messaging system and a compulsory periodic training program. In particular, an online (“e-learning”) training program, for Eni staff, classroom-based training sessions (“general anti-corruption workshops”) and “job specific training” for professional areas at specific risk of corruption. In these courses an overview of the anti-corruption laws applicable to Eni is provided along with an explanation of the tools to identify areas of corruption risk and to apply the control activities that Eni has defined in relation to these areas. Moreover, a description of the reporting methodologies, including Whisteblowing, related to any suspected or known violation of anti-corruption laws or of Eni's Anti-Corruption Compliance Program is provided. Workshops are conducted in areas of high risk of corruption based on the annually index drawn up by Transparency International (Corruption Perception Index) and taking account of Eni’s presence in different areas and contexts. In 2017, the anti-corruption e-learning for managers and other resourses continued; these campaigns are gradually ensuring the involvement of all Eni people. In relation to classroom training, the number of resources involved is increasing as a result of the company's willingness to further strengthen the culture of anti-corruption compliance to allow increasingly effective controls in the areas at risk.
On 10 January 2017, the certification process in Italy of the compliance of Eni’s Anti-Corruption Compliance Program with the requirements of ISO 37001: 2016 “Antibribery Management Systems” was successfully concluded. Published on 15 October 2016, this is the first international standard on anti-corruption management systems. The certification body carried out an audit in two stages to verify, through the examination of documents, the adequacy and design of Eni’s Anti-Corruption Compliance Program, as well as on-the-spot checks and interviews, implementation and operation. Eni SpA is the first Italian company to have received this certification and what enabled Eni to obtain rapid certification of its Anti-Corruption Compliance Program, compared with the publication of the ISO standard, was that Eni first prepared and developed an Anti-Corruption Compliance Program in 2009, in line with applicable international standards and established best practices and guidance on the issue. Finally, in December 2017, the certifying entity performed the surveillance audit provided for under the ISO standard to verify the operation of the Anti-Corruption Compliance Programme, using interviews with the units involved and an examination by the auditors of a sample of documentation. The surveillance audit was completed successfully.
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